JUDGMENT

SYED ARSHAD ALI, JUSTICE:---.---This is a Sales Tax Reference filed by the petitioner-department under section 47 of the Sales Tax Act, 1990 ("Act") seeking advice of this Court on the questions of law framed in the memo. of reference as allegedly arising out of the judgment/order dated 16.12.2021 of the Appellate Tribunal Inland Revenue, Division Bench, Islamabad ("Tribunal").Show-Cause Notice2. The respondent which has established a CNG Filling Station and deals in the sale of natural gas was issued a show-cause notice on 21.09.2019 whereby it was confronted with the following allegations:"According to CHAPTER IV Rule 20(2)(c) of the Sales Tax Special Procedure Rule, 2007, in case of supply of natural gas by a gas transmission and distribution company, the person responsible to charge, collect and deposit sales tax shall be the total amount billed including price of natural gas, charges excluding the amount of late payment surcharge, rents, commissions and all duties and taxes, local...